Air Quality Operating Permit Application
Form 1.0: General Information
INSTRUCTIONS:
Section 1.3: Insignificant Activities
IMPORTANT: Please type or print with black ink. Do NOT use pencil. If you have questions, please
contact the Nebraska Department of Environmental Quality (NDEQ), Air Quality Operating Permit
Team, at (402) 471-2189 or the Air Quality Permitting Hotline at (877) 834-0474. You can also email
your questions to ndeq.airquality@nebraska.gov.
GENERAL INSTRUCTIONS
After reading these instructions, complete Section 1.3, Insignificant Activities List.
As defined in Title 129, Chapter 1, insignificant activities are those activities and emissions that may be
excluded from reporting for operating permit applications and/or emissions inventories. If an insignificant
activity must be included in an operating permit application, the activity can be listed in the application with
a limited amount of support information. The authority to develop a list of insignificant activities comes
from Title 129, Chapter 7, Section 006.03. The NDEQ also has the ability to update the list of insignificant
activities, as necessary.
These instructions include the insignificant activities list. Parts 1 and 2 of these instructions include
insignificant activities that are exempt, or conditionally exempt, from inclusion in both the operating permit
application and the emissions inventory report forms. Parts 3 and 4 include insignificant activities that must
be included in the operating permit application forms, but could potentially be exempt from reporting under
the emissions inventory program.
Please note that, while potentially exempt from inclusion in an Operating Permit Application or the Annual
Emissions Inventory Report, all insignificant activities listed in Parts 1 through 4 of this form must still
be included in the determination of whether a source must obtain a Class I or Class II operating
permit.
Also note that, once the source classification has been determined by the permittee, any activity listed in
Parts 2 through 4 of this form that emits a pollutant(s) subject a synthetic minor limitation is
not an insignificant activity unless the source accepts further limitations on the potential
emissions of the pollutant in question.
EXAMPLE: A source’s potential to emit (PTE) for a single hazardous air pollutant (HAP) is 12.5 tons
per year (tpy) including 1.5 tpy from emissions units qualifying as insignificant activities identified in
Parts 1 through 4 of this form. The source wants to be synthetic minor for HAPs. The source has two
options, which are:
1. Accept a limit of less than 10 tpy for all emissions units and keep records of the HAP
emissions for all units; or,
2. Accept a limit of less than 8.5 tpy, which allows the units be considered insignificant
activities.
In addition to insignificant activities listed in Parts 1 through 4 that emit a regulated air pollutant subject to a
synthetic minor emissions limitation as described above, all emission units that are subject to
applicable requirements, including, but not limited to, NSPS, NESHAP, and/or construction
permit requirements, cannot be considered insignificant activities, as Operating Permits are
required to contain all applicable requirements (Title 129, Chapter 8). For those units subject to an
applicable requirement, you must assign an emission unit identification number, complete the appropriate
emission unit application forms, and calculate and submit emissions as part of your application and Annual
Emission Inventory Reports to NDEQ.
Rev 03/13
Page 1 of 7
08-201-3
Air Quality Operating Permit Application
Form 1.0: General Information
INSTRUCTIONS:
Section 1.3: Insignificant Activities
Engines can no longer be insignificant activities. With the exception of stationary engines being tested at a
stationary test cell/stand, all stationary engines are subject to NSPS, 40 CFR 60 Subpart IIII and/or
NESHAP, 40 CFR 63 Subpart ZZZZ. Therefore, these applicable requirements must be addressed in the
Operating Permit.
If you have engines that are moved around your source, review the following definition of a nonroad engine
from 40 CFR 89.2 and 40 CFR 1068.3:
(1) Except as discussed in paragraph (2) of this definition, a nonroad engine is any internal combustion
engine:
(i)
In or on a piece of equipment that is self-propelled or serves a dual purpose by both propelling
itself and performing another function (such as garden tractors, off-highway mobile cranes and
bulldozers); or
(ii) In or on a piece of equipment that is intended to be propelled while performing its function
(such as lawnmowers and string trimmers); or
(iii) That, by itself or in or on a piece of equipment, is portable or transportable, meaning designed
to be and capable of being carried or moved from one location to another. Indicia of
transportability include, but are not limited to, wheels, skids, carrying handles, dolly, trailer, or
platform.
(2)
An internal combustion engine is not a nonroad engine if:
(i)
The engine is used to propel a motor vehicle or a vehicle used solely for competition, or is
subject to standards promulgated under section 202 of the Act; or
(ii) The engine is regulated by a federal New Source Performance Standard promulgated under
section 111 of the Act; or
(iii) The engine otherwise included in paragraph (1)(iii) of this definition remains or will remain at
a location for more than 12 consecutive months or a shorter period of time for an engine
located at a seasonal source. A location is any single site at a building, structure, facility, or
installation. Any engine (or engines) that replaces an engine at a location and that is intended
to perform the same or similar function as the engine replaced will be included in calculating
the consecutive time period. An engine located at a seasonal source is an engine that remains
at a seasonal source during the full annual operating period of the seasonal source. A seasonal
source is a stationary source that remains in a single location on a permanent basis (i.e., at least
two years) and that operates at that single location approximately three months (or more) each
year. This paragraph does not apply to an engine after the engine is removed from the
location.
For purposes of the above paragraph, the 12-month timeframe does not apply to an engine that is kept at a
staging area/storage. For example, if an emergency generator is kept in a building for deployment when
needed, the time it spends idle in storage is not counted. Only the timeframe when the emergency engine is
at its point of use should be counted. If you have one or more engines that meet the definition of a nonroad
engine, complete Form 6.0, Section 6.2.2. These engines will not be included in your operating permit but
will be discussed briefly in the fact sheet. You do not have to report nonroad engine emissions in your
Annual Emissions Inventory Reports.
Rev 03/13
Page 2 of 7
08-201-3
Air Quality Operating Permit Application
Form 1.0: General Information
INSTRUCTIONS:
Section 1.3: Insignificant Activities
PART 1:
In accordance with Title 129, Chapter 7, Section 006.03, the NDEQ has determined that the following
insignificant activities are exempt from inclusion in the Operating Permit Application and Annual
Emissions Inventory Reports. Please note that these activities are in no way absolved from fulfilling any
other applicable requirements. The NDEQ may request additional information about any activity
exempted by this list, and the permittee is obligated to provide the information requested.
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Rev 03/13
Office Activities, including operation of standard office equipment when such activities are
conducted solely in support of the principal business activity, not including printers or businesses
primarily involved in photographic reproduction
Janitorial activities, services, and consumer use of janitorial products
Maintenance of processing equipment, machinery and/or control devices, buildings, grounds or
facilities to maintain appearance or condition provided these activities are not conducted as part of
a manufacturing process and do not trigger a permit modification
Portable, sealed storage containers that are not connected to a process unit or line by piping,
transfer hoses, lines or valves, etc.
Air conditioning units used for human comfort
Ventilating units used for human comfort that do not exhaust air pollutants into the ambient air
from any manufacturing, industrial, or commercial process.
Non-commercial food preparation
Laundry activities, except for dry-cleaning and steam boilers
Tobacco smoking rooms and areas
Batteries and battery charging stations, except at battery manufacturing plants
Equipment used to mix and package items such as soaps, vegetable oil, grease, animal fat, and
nonvolatile aqueous salt solutions, provided appropriate lids and covers are utilized.
Equipment used exclusively to slaughter animals
Vents from continuous emissions monitors and other analyzers
Hot melt adhesives with no volatile organic compounds (VOC) or hazardous air pollutants (HAP)
in the formulation
Electric or steam-heated drying ovens and autoclaves, but not the emissions from the articles or
substances being processed in the ovens or autoclaves or the boilers delivering the steam
Salt baths using nonvolatile salts that do not result in emissions of any regulated air pollutants
Laboratory equipment used for physical or chemical analysis but not lab fume hoods or vents
Routine calibration and maintenance of laboratory equipment or other analytical instruments
Equipment used for quality control/assurance or inspection purposes, including sampling
equipment used to withdraw materials for analysis
Hydraulic and hydrostatic testing equipment
Environmental chambers not using HAP gases
Shock Chambers, Humidity Chambers, and Solar Simulators
Fugitive emissions related to movement of passenger vehicles, provided the emissions are not
counted for applicability purposes. Additionally, there cannot be a requirement for a fugitive dust
control plan or its equivalent. Any such requirements must be addressed as applicable
requirements in an Operating Permit.
Process water filtration, deionization, and demineralization systems, demineralizer water tanks,
and demineralizer vents
Boiler water treatment operations, not including cooling towers
Oxygen scavenging (de-aeration) of water
Page 3 of 7
08-201-3
Air Quality Operating Permit Application
Form 1.0: General Information
INSTRUCTIONS:
Section 1.3: Insignificant Activities
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Ozone generators
Fire suppression systems, excluding RICE emergency pumps at a fixed site
Emergency road flares
Steam vents and safety relief valves
Steam leaks
Steam cleaning and sterilizer operations
Employee support activities such as cafeteria and recreational facilities
Laboratory and Research and Development Activities conducted exclusively in the non-processing
areas of the source
Storage and handling of lubricating and heavy oils with a vapor pressure less than 0.5 pounds per
square inch (psi) under standard conditions, when held for source use only. The NDEQ asks that
the applicant list the tanks/storage devices, including the tank contents, located at the source in the
second table in Section 1.3 so that the NDEQ is aware of the existence of these tanks/storage
devices at your source.
PART 2:
In accordance with Title 129, Chapter 7, Section 006.03, the NDEQ has determined that the following
activities are conditionally exempt from inclusion in the Operating Permit Application and Annual
Emissions Inventory Reports. The following activities are exempt from inclusion in the Operating
Permit Application and the Annual Emissions Inventory unless the activity emits a pollutant(s) subject
to a synthetic minor emissions limitation. If the activity emits a pollutant subject to a synthetic minor
emissions limitation, the activity must be included in the Operating Permit Application on the
appropriate emission unit form and in the Annual Emissions Inventory Report.
Please note that these activities are in no way absolved from fulfilling any other applicable requirements.
The NDEQ may request additional information about any activity exempted by this list, and the
permittee is obligated to provide the information requested.
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Forges and drop hammers or hydraulic presses used for forging or metal working
Hand-held equipment for buffing, polishing, cutting, drilling, sawing, grinding, turning or
machining wood, metal, or plastic
Brazing, soldering, and welding equipment, and cutting torches related to manufacturing and
construction activities that do not result in emission of HAPs that exceed the reporting level(s) in
Title 129, Appendix II or Appendix III
Pneumatically operated equipment, including hand tools
CO2 lasers, used only on metals and other materials which do not result in emissions of HAPs that
exceed the reporting level(s) in Title 129, Appendix II or Appendix III
Laser trimmers using dust collection and that do not result in emissions of HAPs that exceed the
reporting level(s) in Title 129, Appendix II or Appendix III
PART 3:
In accordance with Title 129, Chapter 7, Section 006.03, the NDEQ has determined that the following
insignificant activities must be included in the Section 1.3: Insignificant Activities List. The emissions
associated with the following activities do not need to be included in the Annual Emissions Inventory
Reports unless the emissions data is requested by NDEQ.
Please note that these activities are in no way absolved from fulfilling any other applicable requirements.
The NDEQ may request additional information about any insignificant activity listed, and the permittee
is obligated to provide the information requested.
1) Comfort cooling towers
Rev 03/13
Page 4 of 7
08-201-3
Air Quality Operating Permit Application
Form 1.0: General Information
INSTRUCTIONS:
Section 1.3: Insignificant Activities
2) Process cooling towers with a circulating water flow rate less than 2,000 gallons per minute. In the
Description column of Section 1.3, include the circulating water flow rate, total dissolved solids
concentration, estimated drift loss, and average hours or days in service.
3) Space heaters. In the Description column of Section 1.3, include the heat input rating, fuel type,
including a summary of annual fuel use for space heating, and number of heaters with the same
rating and fuel type.
4) Fuel storage and distribution equipment, including storage vessels (tanks), with aggregate annual
throughput of less than 1 million gallons for the entire source. Records verifying aggregate annual
fuel oil throughput must be maintained for five (5) years and made available to NDEQ or USEPA
within forty-eight (48) hours of a request for documentation of annual throughput. Please note that
gasoline storage tanks at area sources of HAPs cannot be considered insignificant activities, as
these tanks are subject to NESHAP Subpart CCCCCC (§63.11111). The applicable
requirements for affected units under this subpart must be incorporated into the Operating Permit.
5) Stationary internal combustion turbines at area sources of HAP that are not subject to a NSPS or
NESHAP, use only natural gas as a fuel source, and are rated below 1,630 horsepower. In the
Description column of Section 1.3, please include the size of the unit, the fuel used, and average
hours or days of service.
6) Stationary external combustion units not subject to a NSPS or NESHAP using the listed fuel type
and rated below the corresponding heat input rating. In the Description column of Section 1.3,
include heat input rating of the unit, fuel(s) fired, and average hours or days of service per year.
Fuel Type
Natural Gas
Diesel Oil
No. 2 Fuel Oil
No. 6 Fuel Oil
Coal
Wood
Propane
Kerosene
Heat Input Rating
10.0 Million British Thermal Units per Hour (MMBtu/hr)
8.0 MMBtu/hr
8.0 MMBtu/hr
2.0 MMBtu/hr
1.5 MMBtu/hr
5.5 MMBtu/hr
8.0 MMBtu/hr
8.0 MMBtu/hr
PART 4:
Emission units emitting small amounts of HAPs must be included in the insignificant activities list, but
are excluded from the Annual Emissions Inventory Reports if annual HAP emissions are below the
reporting levels (pounds/year) in Title 129, Appendix II (sorted by CAS number) or Appendix III (sorted
by name). You may see the Appendices on NDEQ Web site http://deq.ne.gov/ under Laws and
Regulations/Rules and Regulations. NDEQ may request that these HAP emissions be reported. When
completing Section 1.3, please place the annual HAP emissions in the Description column.
Sources with synthetic minor HAP limitations must list all HAP emissions units on the appropriate
application forms, unless the source accepts further limitations on their potential emissions that allow an
activity to be insignificant (see example on Page 1 of this form).
Rev 03/13
Page 5 of 7
08-201-3
Air Quality Operating Permit Application
Form 1.0: General Information
Section 1.3: Insignificant Activities List
FACILITY NAME:
DATE:
NDEQ FACILITY ID#:
IMPORTANT: PLEASE READ THE INSTRUCTIONS FOUND IN SECTION 1.3.1 (CLASS I)
OR SECTION 1.3.2 (CLASS II) TO DETERMINE WHICH ACTIVITIES ARE CONSIDERED
INSIGNIFICANT.
Please type responses or use black ink. Do NOT use pencil.
List all insignificant activities located at your facility. Be sure to include enough information in the
description to support the activity’s classification as insignificant. If an insignificant activity has an
assigned emission unit identification number, please include the identification number in the description.
Table 1: Insignificant Activities Summary
Insignificant Activity
Description
Note: Attach additional copies of this table as necessary.
Rev 03/13
Page 6 of 7
08-201-3
Air Quality Operating Permit Application
Form 1.0: General Information
Section 1.3: Insignificant Activities List
SOURCE NAME:
DATE:
NDEQ FACILITY ID#:
Table 2: Storage of Lubricating and Heavy Oils Summary
Storage
ID
Installation
Date
Tank Contents
Maximum
Capacity (gallons)
Vapor Pressure at
Standard
Conditions (psi)
Note: Attach additional copies of this table as necessary.
Rev 03/13
Page 7 of 7
08-201-3